CLA-2-94:CL:PD:CO:TEB:F01

Marsha L. Dawson
Import Manager
Graco Children's Products, Inc.
P.O. Box 100
Elverson, PA 19520

RE: The tariff classification of a Pack N Play Yard with Bassinet and Changing Station from China or Taiwan. Dear Ms. Dawson:

In your letter received on August 20, 1998, you requested a tariff classification ruling.

The furniture item consists of a lightweight portable playpen or play yard designed for use by infants or small children. The product referred to as the Graco Pack N Play has a metal frame to which the textile side and end panels are attached. The mesh fabric in these panels allows the child in the play yard to look outside and permits the supervising adult to see inside in order to monitor the child's activities. Included with the Pack N Play is a manmade fiber sheet sized to fit over the removable padded floor board and a textile mosquito netting sized to fit over the play yard. A photograph accompanied your letter.

The Pack N Play features a bassinet insert frame which can be used to convert the article into a portable bassinet. The insert is covered with a soft textile covering and has a sleeping pad. The

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bassinet attachment is designed to be suspended from the top of the Pack "N Play frame, creating a sleeping environment for the infant which is suspended approximately 18 inches above the playpen floor board. In addition, this bassinet features a removable changing station which easily attaches to the top of the bassinet. The changing station is composed of a metal frame and is covered with padded textile side panels and has a removable wipeable vinyl pad and safety belt. The Pack N Play Yard with bassinet and changing station is designed to be placed on the floor or ground. Each of the components are parts adapted one to another to form a complete unit and would be considered composite goods. The essential character of the play yard is imparted by its textile components. The applicable subheading for the bassinet will be 9403.80.6040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for furniture of other materials; other; household. The duty rate will be 0.8 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

This ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have already been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

John M. Regan
Service Port Director
Cleveland, Ohio